Taxpayers and practitioners welcomed the IRS announcement on June 18, 2014 of the new offshore compliance program and streamlined procedures, but questions remain regarding many of the provisions. This panel will address the "gray" areas of the 2014 OVDP, willfulness certifications, the calculation of penalties under transition relief, the increased penalties where a taxpayer's bank is the subject of a public announcement by the IRS or DOJ, and the eligibility for and calculation of reduced penalties under the new streamlined procedures.